ML20049H552
| ML20049H552 | |
| Person / Time | |
|---|---|
| Issue date: | 11/30/1981 |
| From: | Hebdon F NRC OFFICE OF MANAGEMENT AND PROGRAM ANALYSIS (MPA) |
| To: | |
| References | |
| TASK-1.E.6, TASK-TM NUDOCS 8203030287 | |
| Download: ML20049H552 (9) | |
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1 Licensee Event Report (LER) Rulemaking TMI Action Plan Item I.E.6 4
by i
Frederick J. Hebdon I
Office for Analysis and Evaluation I
of Operational Data U.S. Nuclear Regulatory Commission i
Presented at American Nuclear Society i
Winter Meeting j
i November 30, 1981
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B203030287 811130 PDR ORO EPSANS PDR
o ABSTRACT In September 1981, the Nuclear Regulatory Commission decided to defer a proposed rulemaking action which would have required utilities licensed to operate nuclear power plants to submit data to an Integrated Operational Experience Reporting (10ER) system. The system, proposed in January 1981, would have combined the NRC's Licensee Event Report (LER) system and the utility industry's Nuclear Plant Reliability Data (NPRD) system into a single mandatory reporting system.
Prior to proposing the rulemaking in January, the NRC staff had identified two principal shortcomings'in NPRD system:
(1) utilities were interpreting the reportable data differently, and (2) there was a low level of participation by the utilities.
Recent events now indicate that the NRC may be able to obtain the needed reliability data without assuming direct responsibility for its collection.
The industry's Institute of Nuclear Power Operations (INP0) in Atlanta, Georgia, has decided to a:sume responsibility for managing and funding the NPRD system and will also develop critieria for assessing the adequacy of utility participation in the NPRD system. The Commis-sion has decided to proceed only with the development of a proposed rule that will modify and codify existing LER reporting requirements.
However, if in the future it becomes clear that NRC neeas for reliability data are not being met by the NPRD system, the Commission will consider specific alternatives, including resumption of rulemaking for the 10ER system.
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1.0 INTRODUCTION
In December 1980, the Commission agreed that the reporting of operational experience data needed major revision, and approved the development of the Integrated Operational Experience Reporting (I0ER) system.
The 10ER system would have combined, modified and made mandatory the existing Licensee Event Report (LER) system and the Nuclear Plant Reliability Data (NPRD) system.
As a result of the Commission approval of the concept of the 10ER system, an Advance Notice of Proposed Rulemaking (ANPRM) was published in the Federal Register on January 15, 1981 (46 FR 3541).
That ANPRM explained why the NRC needed operational experience data, and described the deficiencies in the existing LER and NPRD systems.
In June 1981, the Institute of Nuclear Power Operations (INP0) announced plans to assume responsibility for the management technical direction and funding of the NPRD system.
In respon e to this announcement, the NRC staff recommended (SECY 81-494) and the Commission approved a revision to the program for collecting operational experience. This revised program requires that the NRC staff:
(1) Defer rulemaking that would establish the 10ER system; (2)
Develop for Commission review and approval a proposed rule to modify and codify the existing Licensee Event Report (LER) reporting requirements and to assure consistency with 10 CFR 50.72, which covers the immediate reporting of significant events; (3)
Bring a revised LER rule to the Commission before the end of 1981; (4)
Endorse INP0's plan to assume responsibility for the management, funding, and technical direction of the NPRD system; (5) Coordinate closely with INP0 to minimize duplication between the LER and the NPRD systems, and between subsequent NRC and INPO analysis of NPRDS data; (6)
Encourage INP0 to assure that the NPRD system receives, processes, and disseminates the reliability data needed by industry and the NRC to support probabilistic risk and reliability assessment programs; and I
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Provide the Commission with semi-annual status reports on the effective-ness of INP0 management of NPRDS and the responsiveness of NPRDS to NRC t
needs.
As a result of the Commission approval of this approach to the collection of I
operational experience data, an Advanced Notice of Proposed Rulemaking (ANPRM) l was published in the Federal Register on October 6, 1981 (46 FR 49134).
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2.0 BACKGROUND
The accident at Three Mile Island (TMI) focusec s tention on the importance of an ef fective understanding and feedback of cperai.ing experience.
Studies of the TMI accident (e.g., Rogovin, Kemeny) emphasized the importance of collecting and evaluating operational experience.
In addition, other studies, particularly a study by the ACRS (NUREG-0572, Review of Licensee Event Reports), identified weaknesses in the existing program and recommended corrective actions.
Based on the recommendations contained in these reports, and on its own analyses, the NRC staff decided that the reporting of operational data needed major revision in terms of scope, content, and method of reporting.
2.1 N_uclear Plant Reliability Data (NPRD) System The present NPRD system is a voluntary program for the reporting of reliability data associated with Safety Class 1, 2 and IE components and cystems in nuclear pcwer plants.
It is cu;' ently operated by the Southwest Research Institute under a contract which is joincly funded by NRC, the Edison Electric Institute, American Public Power Association, and the Tennessee Valley Authority.
Efforts to make participation in NPRDS mandatory began as a result af furmer President Carter's 1977 National Energy Plan which recommended that the NRC make mandatory the present voluntary reporting of minor mishaps and component failures (i.e.,NPRDS). The plan suggested that mandatory participation would enable industry and the NRC to develop a more reliable data base which is needed to improve reactor design, construction, operation, safety, and reliability.
Coincident with the NRC's activities directed toward implementing the President's recommendation, the General Accounting Office (GA0) reviewed the NRC's data-gathering activities concerning unscheduled events at commercial nuclear facilities.
In a report issued in late January 1979, the GA0 concluded that l
it was unlikely that the NRC could justify mandatory NPRDS participation when factors such as additional industry costs, limited expected safety benefits, and duplication of the NRC's LER system were considered.
however, the GA0 believed that a full examination of the issue was warranted and suggested that the issue be decided using rulemaking procedures.
The GA0 concluded that rulemaking would provide the nuclear industry and the public, as well as the NRC staff, the opportunity to get their views on record and would better ensure that all of I
these views were properly considered by the Commisson.
GA0 considered this to be particularly important since it believed that the reliability data system had been developed and operated primarily by industry for industry's benefit.
Following an April 19, 1979 Commiss' ion briefing on operational safety data gathering and analysis, the Commission concurred with the January 1979 GA0
. recommendation that rulemaking be used to decide the question of whether or not to make NPRDS reporting mandatory.
Accordingly, an Advance Notice of Proposed Rulenaking (ANPRM) was prepared, presented to and approved by the Commission (SECY 79-604), and published in the Federal Register on January 30, 1980 (45 FR 6793).
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Nunerous public comme'nt letters were r'ceive'd in response to the ANPRM.
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predominant message in the comments was an overwhelming opposition to making participation in NPRDS mandatory.
In addition, the staff found that the NPRDS as implemented did not fulfill the NRC's objectives because of a number of fundamental deficiencies:
(1) Although the reportable scope is defined as Safety Class 1, 2, and IE, utilities interpreted this requirement differently in determining specifically which components should be included in NPRDS.
For example, the number of components reported by various plants varies from 1500 compcnents per plant to almost 5000 components per plant.
(2)
Participation is low and thus data are sparse.
(3)
The scope of NPRDS does not include all components of interest (e.g.,
Safety Class 3 components, balance-of-plant systems, vessel internals, and certain sizes of pipes and valves).
(4) A large percentage of the data reported to NPRDS duplicate that reported to the LER system.
Despite the opposition to a mandatory system and the shortcomings noted above, the staff identified a strong need for failure rate and engineering data. The requirement for such data indicated a need to revise and reorient the system, in combination with the existing LER system, and to assure its effective implementation through NRC rulemaking.
I 2.2 Licensee Event Report (LER) System l
There were approximately 3,500 LERs submitted in calendar year 1980 and the number is expected to steadily increase as new plants begin operation.
Review of these LERs indicated a number of deficiencies and shortcomings, such as:
(1)
The scope does not include all systems important to safety.
l (2)
The scope covers components only while the technical specification l
(i.e., normal ) service.
Defects found during non-technical specifi-cation inspections or during shutdown are not always reported.
(3) Many events that are not individually significant are reported.
Although such events may be important because of their frequency of occurrence or because they indicate trends and patterns, they tend to distract from the few significant events that require detailed engineering analysis or in-depth study.
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. (4)
The format of the LER form is oriented toward computerized data processing of a single component failure rather than toward a technical engineering analysis of the event.
Consequently, the staff recognized that major revisions in the LER system were also warranted.
The most efficient way to make the necessary modifications was to make a single uniform set of requirements through a rulemaking proceeding.
2.3 Integrated Operdtional Experience ~ Reporting (10ER) System In order to obtain the necessary improvements in the LER and NPRDS reporting programs, the staff developed conceptually a revised reporting system.
This 10ER system would have combined and restructured the NRC LER system and the voluntary NPRD system.
The IDER system would have been composed of t" ee parts:
the Operational Event Report (0ER); the Engineering Data Report (EDR); and the Reliability Data Report (RDR).
The OER would have been a detailed narrative description of safety significant events.
It would have provided the basis for the study of more serious events that might be precursors to serious accidents, by describing in detail the event and planned corrective action.
The second part of the 10ER System, the EDR, would have established a data base of
" pedigree" information.
The EDR would have been submitted only once, after the reactor's initial fuel loading, to establish a comprehensive description of the components, subsystems, and systems considered important with regard to safety which are in use within the plant.
The third part of the 10ER System, the RDR, would have been a computer-oriented report collecting failure data on the components, subsystems, and systems contained in the engineering data base. The data would have been used in quantitative risk assessment techniques such as fault tree analysis.
The revised reporting requirements would have been implemented through rule-making to assure uniform requirements, efficient utilization of staff resources, and adequate review and comment.
3.0 LER RULEMAKING The 10ERS concept included two principal featuies:
(1) the collection of detailed l
technical descriptions of significant events, and (2) the collection of component reliability data.
While the staff still believes that both types of data are essential to the NRC mission, recent events have indicated that the NRC can obtain the needed reliability i
data without assuming direct responsibility for its collection.
On June 8, 1981, l
the INP0 Board of Directors decided that because of its role as an active user i
of NPRDS data, INP0 will assume responsibility for management and funding of l
NPRDS. Further, INP0 is developing criteria that will be used in their manage-l ment audits of member utilities to assess the adequacy of NPRDS participation.
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The principal deficiencies that had previously made NPRDS an inadequate source of reliability data were the inability of a committee management struc-ture to provide the necessary technical directior, and a low level of partici-pation by utilities. The recent commitments and actions by INP0 provide a basis for confidence that these two deficiencies will be corrected.
For example, centralizing the management and funding of NPRDS within INP0 should overcome the previous difficulties associated with management by a committee and funding from several independent organizations.
Further, with INP0 focusing on a utility's participation in NPRDS as a specific evaluation parameter during routine management and plant audit activities, the level of utility participation, and thus, the quality and quantity of NPRDS data, should significantly increase.
Finally, the NRC staff will continue to have an active role in the development of an effective NPRDS by participating in a planned NPRDS Technical Advisory Committee, by periodically assessing the quality and quantity of information produced by NPRDS, and by assuring timely availability of the information to the NRC staff.
Therefore, rather than pre-empt the INP0 activities by proceeding with the I0ERS rulemaking, the staff believes it is appropriate to proceed only to modify and codify the existing LER reporting requirements as a separate rulemaking and to hold the 10ERS rulemaking in abeyance.
Thus, the NRC will reduce the number of LERs by eliminating the requirement for LER reports for most component failures or malfunctions covered by the NPRDS. The NRC will require LERs only for those individual component failures or malfunctions that are of major safety significance.
However, the technical content of each report will be substantially improved by requesting a technically detailed and comprehensive report suitable for an engineering review.
- Thus, the LER system, which was not designed to produce reliability data, will no longer attempt to provide a basis for equipment reliability studies; the NPRDS, which is designed to produce such reliability data, will perform this service.
The troubled history of the NPRDS makes the staff cautious; problems will not be resolved simply by having INP0 take over direction of the NPRDS.
Never-theless, the people at INP0 and the cognizant NRC staff are well aware of the problems and are prepared to work together to assure successful redirection of NPRDS.
If in the future, however, it becomes clear that the essential NRC needs for reliability data are not forthcoming from NPRDS, the staff will provide specific recommendations at that time.
These recommendations could include resumption of the 10ERS rulemaking to make the reporting of reliability data mandatory.
In summary, since there is a reasonable likelihood that NPRDS under INP0 direction can meet the NRC's need for reliability data in the future, there
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' is no longer a need to proceed with the 10ERS rulemaking in order to collect i
reliability data. Consequently, the collection of detailed technical descrip-tions of significant events can proceed as a separate LER rulemaking to modify and codify the existi0g LEP reporting r,equirements and to assure consistency with 10 CFR 50.72 covering the immediate notification of significant events.
4.0 FUTURE PLANS AND SCHEDULE The Commission has directed that the staff prepare a proposed LER rule by December 31, 1981. After review and approval by the Commission, the proposed rule will be published in the Federal Register for public review and comment.
.i After review of the comments by the NRC staff and appropriate changes to the proposed rule, the staff will submit a final rule to the Commission in late 1982.
If approved by the Commission, the final role could become effective by the end of 1982.
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UNITED STATES l
f NUCLEAR REGULATORY COMMISSION 1
WASHINGTON. D.C. 20555 y
MEM0 FOR:
Jim McKnight, DMB FROM:
P. Larkins, TIDC J. Resner, TIDC
SUBJECT:
Transmittal of Speeches Attached are two copies of a speech to be sent to the PDR and TERA. We have filed the NRC Form 426.
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